Article 6 routing plus current statutory dates
This router uses Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744 and the Commission draft high-risk classification guidelines published on 19 May 2026. It keeps classification triage separate from date mapping: Article 6(2) / Annex III systems are mapped to 2 December 2027, while Article 6(1) / Annex I product-integrated systems are mapped to 2 August 2028.
Open Regulation (EU) 2026/1744
Open Commission draft guidelines
Open consultation record
Route the system before you argue the answer.
High-risk classification starts with the route. Product-integrated AI, Annex III people-impact use cases, narrow Article 6(3) derogation arguments, and incomplete vendor files require different evidence records.
Annex I product route
Use this path when the AI system is itself an Annex I product or is intended as its safety component, and verify whether the relevant product requires third-party conformity assessment.
Annex III use-case route
Use this path when the intended purpose matches a listed Annex III use case. An industry or area label alone is not enough.
Article 6(3) derogation filter
Use this path only for an Annex III system where the no-significant-risk condition and at least one statutory task condition may be met. Profiling prevents reliance on this derogation.
What the draft guidance changes for practical triage
This table is written for both human readers and AI answer engines. Each row gives a direct classification signal and the operational action to record.
| Intended purpose matters | Check the system description, instructions, marketing claims, sales materials, terms, and technical documentation. Do not classify only from the buyer’s internal label. |
|---|---|
| Routes are independent | Assess possible Article 6(1)/Annex I and Article 6(2)/Annex III routes separately. One route does not suppress the other. |
| Human review is not a shortcut | Record how the AI output influences the human decision. Human review may support oversight, but it does not automatically remove high-risk review. |
| Article 6(3) is a downstream record | The router only identifies when the Annex III-only Article 6(3) derogation may need review. Build the detailed rationale on the Article 6(3) Filter Decision Record page. |
| Profiling has a defined scope | For an Annex III system, profiling of natural persons prevents reliance on Article 6(3). Profiling alone does not place every AI system in Annex III or make it high-risk. |
| Split workflows still count | Draft Commission guidance recommends assessing connected components as a complete workflow. Treat that interpretation as draft, non-binding support rather than a statutory branch. |
Build a high-risk classification triage record.
Answer 13 questions. The result gives a review route, triggered factors, evidence to retain, vendor questions, and the next EU AI Compass tool to open.
Prerequisite: this router does not assess or clear Article 5 prohibited practices. Check Article 5 separately before relying on an Article 6 route.
Move from classification route to evidence record.
A router result is useful only if it becomes a retained decision record. Use the next tool that matches your output.
High-risk classification questions
These answers cover the router’s scope, limits, evidence outputs, and the common mistake of treating human review as a classification shortcut.
No. The EU AI Act High-Risk Classification Router gives an operational triage route based on the information entered and the source basis reviewed. It does not provide legal advice, certify compliance, or make a final classification decision.
The router evaluates possible Article 6(1)/Annex I and Article 6(2)/Annex III routes independently, then considers Article 6(3) only for an indicated Annex III route. It does not assess or clear Article 5 prohibited practices. The output is a review route, not a legal conclusion.
No. Human review may matter for governance and oversight, but human review alone does not automatically remove an AI system from high-risk review. Intended purpose, use context, profiling, and decision influence still need to be checked.
The Article 6(3) filter is a downstream review path for some Annex III systems. The router only flags when that path may need review. Use the Article 6(3) Filter Decision Record to document task type, profiling, material influence, human assessment, and evidence gaps.
Intended purpose matters because classification review looks at what the AI system is designed, documented, marketed, sold, and used to do. Product documentation, instructions, sales materials, and technical descriptions can widen or narrow the review route.
Keep the intended-purpose statement, role assumption, Annex I or Annex III route rationale, Article 6(3) filter rationale where relevant, vendor documentation, human oversight note, profiling note, reviewer name, and review date.
Use the result as a routing record, not a final answer.
Run the router, then move the output into an inventory entry, vendor evidence request, or deployer evidence file. Complex systems, product-integrated AI, agentic workflows, profiling, or contested Article 6(3) positions need qualified review.
Run another systemSource basis and limits: This page is based on the consolidated Regulation (EU) 2024/1689 dated 27 July 2026, Regulation (EU) 2026/1744, and the European Commission draft guidelines on high-risk AI classification published on 19 May 2026. The draft guidance is non-binding and its examples are non-exhaustive; the consultation closed on 23 July 2026. Article 6(2)/Annex III provisions apply from 2 December 2027 and Article 6(1)/Annex I provisions apply from 2 August 2028. Last reviewed: 3 September 2026. This page is educational and operational triage only. It is not legal advice, official EU guidance, conformity assessment, certification, or a compliance guarantee. Consult qualified legal, privacy, sector, product-safety, or security professionals before making binding decisions.